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Tax Research (Day 1) Dr. Richard Ott ACCTG 833, Fall 2007

1. Chapter. Tax Research (Day 1) Dr. Richard Ott ACCTG 833, Fall 2007. Tax Research Process. Contexts: Closed-fact or tax compliance situations Open-fact or tax planning situations. Tax Research Process. Goal of tax planning: Maximize NPV of after-tax cash flows Must consider:

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Tax Research (Day 1) Dr. Richard Ott ACCTG 833, Fall 2007

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  1. 1 Chapter Tax Research(Day 1)Dr. Richard OttACCTG 833, Fall 2007

  2. Tax Research Process • Contexts: • Closed-fact or tax compliance situations • Open-fact or tax planning situations

  3. Tax Research Process • Goal of tax planning: • Maximize NPV of after-tax cash flows • Must consider: • Tax consequences to all parties • Nontax costs • Financial reporting consequences (publicly traded corporations)

  4. Tax Research Process • Determine the Facts • Identify issues and research questions • Locate applicable authorities • Evaluate authorities (conflicts) • Analyze facts in terms of the authorities • Communicate conclusions and recommendations (usually written)

  5. Sources of Tax Law • Statutory authorities • Administrative authorities • Judicial authorities

  6. Statutory Authorities

  7. Statutory Authorities • U.S. Constitution, 16th Amendment (1913) • Tax Treaties • The Internal Revenue Code

  8. Internal Revenue Code • The Internal Revenue Code is the law as enacted by Congress, signed by President • Highest weight of authority in conflicts

  9. Internal Revenue Code • The Internal Revenue Code is Title 26 of the U.S. Code and is organized as follows: A. Subtitles 1. Chapters C. Subchapters III. Parts A. Subparts 351 Sections

  10. The Internal Revenue Code • Sections are numbered sequentially from the beginning to the end of Title 26 and are divided as follows: 351 Section (g) Subsections (1) Paragraphs (A) Subparagraphs (i) Clauses

  11. The Internal Revenue Code • Examples of acceptable citations: Internal Revenue Code §351(g)(1)(A)(i) IRC §351(g)(1)(A)(i) IRC Section 351(g)(1)(A)(i) Code §351(g)(1)(A)(i) Code Section 351(g)(1)(A)(i) Section 351(g)(1)(A)(i) of the IRC Section 351(g)(1)(A)(i) of the Code 26 USC §351(g)(1)(A)(i)

  12. For Next Class: • Read Chapter 1 through page 1-13 in the Prentice Hall textbook • Note to self: There was ½ hour of extra class time available on each of Days 1 and 2 and 20 minutes extra time on Day 3. Next time combine Chapter 1 into just 2 days.

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